Tax treaties

The Platform for Collaboration on Tax invites public comments on the draft Toolkit on Tax Treaty Negotiations


UPDATE 09/09/2020  - The PCT has extended the deadline for the public consultation on its draft Toolkit on Tax Treaty Negotiations. The public consultation on the Toolkit on Tax Treaty Negotiations is now accepting submissions until Thursday, 24 September 2020.

UPDATE 31/07/2020 - The draft version of the Toolkit on Tax Treaty Negotiations is now also available in French and Spanish.




29/06/2020 - The Platform for Collaboration on Tax (PCT) – a joint initiative of the IMF, OECD, UN and World Bank Group – is seeking feedback from the public on a draft toolkit designed to help developing countries build capacity in tax treaty negotiations.


PCT's Draft Toolkit on Tax Treaty Negotiations is a joint effort to provide capacity-building support to developing countries on tax treaty negotiations, building on existing guidance, particularly from the UN Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (the "UN Manual"). The Toolkit describes the steps involved in tax treaty negotiations such as how to decide whether a comprehensive tax treaty is necessary, how to prepare for and conduct negotiations, and what follow-up measures to take after negotiations. Treaty negotiating teams, especially those who are new to the process, can also find practical tips on the conduct of negotiations and negotiation styles.


Additionally, the Toolkit collates links to publicly available resources that treaty negotiators will find useful, making them easily accessible for treaty teams. The design of the Toolkit allows regular updates and improvements based on the feedback from users and experienced negotiators.


The PCT Secretariat is now seeking comments on the discussion draft of the Toolkit by 24 September 2020 from interested stakeholders. Comments can be sent in two ways:

  • All interested stakeholders: Please send your comments by e-mail to
  • Tax administrations and international or regional tax organisations can also provide their comments on the Knowledge Sharing Platform for Tax Administrations Web site (KSP-TA) by registering HERE


The PCT Secretariat aims to release the final toolkit in early 2021. French and Spanish versions of the discussion draft of the Toolkit will also follow. For more information on the public comment process, please visit the PCT's official website.


Please note that all comments received will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.


Media queries should be directed to: